Cost Accounting Standards
Cost Accounting Standards are a set of 19 standards and rules promulgated by the United States Government for use in determining costs on negotiated procurements. CAS differs from the Federal Acquisition Regulation in that FAR applies to substantially all contractors, whereas CAS applies primarily to the larger ones.
History
In 1970, Congress established the original Cost Accounting Standards Board to promulgate cost accounting standards designed to achieve uniformity and consistency in the cost accounting principles followed by defense contractors and subcontractors in excess of $100,000, and to establish regulations to require defense contractors and subcontractors, as a condition of contracting, to disclose in writing their cost accounting practices, to follow the disclosed practices consistently and to comply with promulgated cost accounting standards.After adopting 19 standards, the original CASB was dissolved on September 30, 1980; the standards, however, remained active and the CASB was revived in 1988 within the Office of Federal Procurement Policy. The current CASB consists of five members: the OFPP Administrator and one member from the United States Department of Defense, the General Services Administration, industry, and the private sector.
The Standards
The original CASB adopted 19 standards, numbered 401 through 420. The new CASB readopted the original 19 standards with only minor modifications, and has yet to adopt any new standards.Standard | Title |
401 | Consistency in Estimating, Accumulating and Reporting Cost |
402 | Consistency in Allocating Costs Incurred for the Same Purpose |
403 | Allocation of Home Office Expenses to Segments |
404 | Capitalization of Tangible Assets |
405 | Accounting for Unallowable Costs |
406 | Cost Accounting Period |
407 | Use of Standard Costs for Direct Material and Direct Labor |
408 | Accounting for Costs of Compensated Personal Absence |
409 | Depreciation of Tangible Capital Assets |
410 | Allocation of Business Unit General and Administrative Expenses to Final Cost Objectives |
411 | Accounting for Acquisition Costs of Material |
412 | Composition and Measurement of Pension Costs |
413 | Adjustment and Allocation of Pension Cost |
414 | Cost of Money as an Element of the Cost of Facilities Capital |
415 | Accounting for the Cost of Deferred Compensation |
416 | Accounting for Insurance Cost |
417 | Cost of Money as an Element of the Cost of Capital Assets Under Construction |
418 | Allocation of Direct and Indirect Costs |
419 | unused |
420 | Accounting for Independent Research and Development Costs and Bid and Proposal Costs |
CAS Applicability
CAS applies to contracts, not contractors, through Federal Acquisition Regulation clauses. A company may have contracts that are subject to "full" CAS coverage, "modified" CAS coverage, simultaneously have contracts that are subject to either modified or full coverage, or be exempt from coverage. However, a company under "full" coverage is not subject to a standard where it does not apply."Modified" coverage applies to contracts when a company receives a single CAS-covered award of US$7.5 million or more; this is known as the "Trigger" contract; modified coverage applies to all contracts that are not exempt from CAS until the company meets the criteria for "Full" coverage.
"Full" coverage applies when a company receives either one CAS-covered contract of US$50 million or more in the current accounting period, or, in the preceding cost accounting period, multiple CAS-covered contracts cumulatively totaling US$50 million. In addition to complying with all 19 standards, the company must also file a CAS Disclosure Statement, which spells out the company's accounting practices. There are two versions of the CAS Disclosure Statement: DS-1 applies to commercial companies while DS-2 applies to educational institutions.
In some instances, a contract may be exempt from CAS standards:
- Contracts awarded to small businesses are exempt from CAS, regardless of contract size.
- Any contract less than US$750,000 is always exempt.
- Any contract less than US$7.5 million is exempt, provided the company has not been awarded a contract greater than US$7.5 million in the past.
- Contracts for commercial items
- Contracts awarded under sealed bid procedures, or where "adequate price competition" was available
- Contracts where the price is set by law or regulation
- Contracts awarded to foreign governments
- Contracts awarded to foreign concerns
Furthermore, in some instances even where a company is subject to a standard, different rules may apply within the standard itself as to what a company is required to do. As an example, under CAS 403, if Company A's "residual expenses" exceed a specified percentage of revenue, Company A must follow a dictated "three-factor" formula to allocate such expenses, but if Company B's residual expenses do not exceed the percentage, Company B may follow the formula but is not required to do so.